SECTION 1. PURPOSE
Internal Revenue Bulletin 2014-9 · 2026-10-03 edition · updated 2026-10-04 · United States
This revenue procedure provides a safe harbor under which the Internal Revenue Service (the “Service”) will treat indebtedness that is secured by 100 percent of the ownership interest in a disregarded entity holding real property as indebtedness that is secured by real property for purposes of § 108(c)(3)(A) of the Internal Revenue Code.
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